August 22, 2016
The Coalition submitted comments to CMS regarding Medicare Program; Changes to the Medicare Claims and Entitlement, Medicare Advantage Organization Determination, and Medicare Prescription Drug Coverage Determination Appeals Procedures; Proposed Rule, recommending that CMS address their backlogged appeals process and minimize improper denials of Medicare contractor appeals. The Coalition suggested accomplishing this by means of proposals to improve broad audits and contractor reviews. Further, the Coalition advocated for a prohibition on contractors collecting provider overpayments until the appeals process has been exhausted on all levels. The Coalition also supported:
  • Mandatory education and training for all providers and Medicare contractors
  • The creation of a process for interested stakeholders to challenge published case precedent
  • The assurance that attorney adjudicators will have experience in Medicare coverage, coding, and payment and that those attorneys, too, receive continuous education and training on these issues. 
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